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TREAS/IRS

RIN: 1545-AK74

Publication ID: Fall 2014

Title: Foreign Corporations
Abstract: The income tax regulations under section 367 will be amended to reflect the changes made to that section by the Tax Reform Act of 1984. Section 367 now provides generally that a foreign corporation will not be considered to be a corporation, for purposes of certain nonrecognition provisions of the Internal Revenue Code (Code), upon the transfer of property to such corporation by a U.S. person. The statute provides certain exceptions to that rule, exemptions to those exceptions, and special rules applicable to certain specified transfers. The regulations will provide guidance concerning the applicability of the general rule and its exceptions and special rules, including guidance concerning transfers of assets for use in the active conduct of a trade or business, stock transfers, transfers of intangible assets, and transfers of branch operations that have operated at a loss.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Final Rule Stage
Major: No	Unfunded Mandates: No
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 367 26 USC 7805

Legal Deadline: None

Timetable:

Action	Date	FR Cite
NPRM	05/16/1986	51 FR 17990
Final Action	12/00/2014

Additional Information: REG-209042-86 (INTL-610-86) Drafting attorney: Ryan Bowen (202) 622-3860 Reviewing attorney: Charles P. Besecky (202) 622-3860 CC:INTL
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
RIN Data Printed in the FR: No
Agency Contact: Ryan Bowen Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6937 Fax:202 317-4922 Email: ryan.bowen@irscounsel.treas.gov